REV05756

• Permit No: C1980006
• IBM Index Class Name: Revision
• Doc Date: 10/3/1989
• Doc Name: KERR PR C-80-006
• From: MLRD
• To: CATHY BEGEJ
• Type & Sequence: PR1
• Media Type: D
• Archive: No

iii iiiiiiiiiiiu iii
STATE OF COLO:v-~L~U
Roy Romer, Gove
DEPARTMENT OF NATURAL RESOURCES
MINED LAND RECLAMATION DIVISION
FRED R, BANTA, Director
DATE: October 3, 1989
T0: Cathy Begej
FROM: Tim King /~
RE: Kerr Permit Revision, C-80-006
After careful review of this permit revision, sent by Kerr Coal Company for
this Marr Mine, I find serious faults with this plan that, in my estimation,
cannot allow it to be approved. "
In volume 2, Rule 2.05, "Operation and Reclamation Plans", page 2.05.3 - 33,
Kerr proposes two permanent overburden stockpiles, stating that they will
conform to all reclamation standards. Page 2.05.3-49 states that their
overburden stockpiles "have been designed as an integral part of the planned
postmining topography *to blend with surrounding reclaimed and undisturbed
terrain." Page 2.05.3- s a es "The final surface of the overburden
stockpiles will be left in a *rough graded condition to minimize overland flow
and prevent erosion." Rule 1. o e requires that this area
" .. closely *resembles the general surface configuration of the land prior to
mining and *blen s in o and compliments the drainage pattern of the
surrounding terrain with all the highwalls and spoil piles eliminated." The
revision then refers to Map 38, "Postmining Topography Map" which illustrates
the proposed overburden stockpiles after mining. The configuration of the
stockpiles appears to show that they do not closely resemble the general
surface configuration and do not blen wi the surrounding reclaimed area.
This map also depicts vestiges of highwalls in place, not eliminated as
required. I am unable to visualize any back filled pits, eliminated
spoilpiles, or eliminated highwalls from this map.
On page 2.05.4-15 of this same volume, Kerr Coal Company refers to pre-mining
topography characterized by rolling hills and steep rocky ridges
intersected by a relatively deep ephemeral stream channels .. Map 38
appears to show o-ther topography, lacking steep rock ridges and deep stream
channels. Also on this same map, Kerr appears to show more than one drainage
proceeding through two 90° turns as well as travelling directly through the
bottom of the pit. Other drainages are shown as completely cut off uphill
from the pit and resuming downhill from the pit. It shows no drainage path
within the pit area Kerr appears to neglect any address of this within this
revision.
* - Emphasis added.
215 Centennial Building, 1313 Sherman Street Denver, Colorado 80203-2273 Tel. [phone]